When is a "disclosure accounting" required under HIPAA?

A "disclosure accounting" under HIPAA, which refers to the requirement for covered entities to account for disclosures of protected health information (PHI) made without patient authorization, is essential for ensuring transparency and allowing individuals to understand how their information is shared. This process is specifically triggered when PHI is utilized for research purposes without the necessary authorization, except in cases where limited data sets are used. Limited data sets are less comprehensive and do not contain direct identifiers, which alleviates the need for disclosure accounting in such situations.

The requirement emphasizes the importance of individuals' privacy rights and their ability to track how their personal health information is accessed. This accounting must be provided upon request by the individual whose information was disclosed, allowing for oversight and helping to maintain trust in the research process.

This understanding of when disclosure accounting is necessary helps underscore the legal obligations placed on researchers handling PHI, ensuring compliance with HIPAA regulations.